Determination of an Application for an Environmental Permit under the Environmental Permitting (England & Wales) Regulations 2010 Decision document recording our decision-making process The application number is: PAN-000045 The permit number is: EPR/BU2489IT The variation number is: EPR/BU2489IT/V009 The applicant / operator is: Intertissue Limited The installation is located at: Intertissue Neath Brunel Way Baglan Energy Park Briton Ferry Neath SA11 2HZ What this document is about This is a decision document, which accompanies the consolidated permit and variation and consolidation notice. It explains how we have considered the applicant’s application, and why we have included the specific conditions in the consolidated permit we have issued to the applicant (hereafter referred to as the operator). It is our record of our decision-making process, to show how we have taken into account all relevant factors in reaching our position. Unless the document explains otherwise, we have accepted the operator’s proposals. Preliminary information and use of terms We gave the application the reference number PAN-000045. We refer to the application as “the application” in this document in order to be consistent. The number we have given to the permit is EPR/BU2489IT. We refer to the permit as “the permit” in this document. The application was duly made on 14th December 2015. Intertissue Neath Page 1 of 51 EPR/BU2489IT/V009 The applicant is Intertissue Limited. We refer to Intertissue Limited as “the applicant” in this document. Where we are talking about what would happen after the variation is issued, we call Intertissue Limited “the operator”. Intertissue Limited’s facility is located at Intertissue Neath, Brunel Way, Baglan Energy Park, Briton Ferry, Neath, SA11 2HZ. We refer to this as “the installation” in this document. Intertissue Neath Page 2 of 51 EPR/BU2489IT/V009 How this document is structured Glossary of acronyms Our decision How we reached our decision o Receipt of the application o Consultation on the application The legal framework The installation o Description of the installation and related issues o The permitted activities o The site o What the installation does o Key Issues in the determination o The site and its protection o Site setting, layout and history o Proposed site design: potentially polluting substances and prevention measures o Closure and decommissioning o Operation of the Installation – general issues o Administrative issues o Management o Site security o Accident management o Off-site conditions o Operating techniques o Energy efficiency o Efficient use of raw materials o Avoidance, recovery or disposal of wastes produced by the activities Minimising the installation’s environmental impact o Air quality assessment o Human health risk assessment o Impact on habitats sites, SSSIs, non-statutory conservation sites etc. o Impact of abnormal operations Application of Best Available Techniques o Combustion unit and control of emissions to air o Emissions to water o Emissions to land or groundwater. o Emissions to sewer o Fugitive emissions o Odour o Noise and vibration o Global warming potential Setting ELVs and other permit conditions o Translating BAT into permit conditions o National and European EQSs o Global Warming o Commissioning Intertissue Neath Page 3 of 51 EPR/BU2489IT/V009 o Monitoring o Monitoring during normal operations o Monitoring under abnormal operations arising from the failure of the installed CEMs o Reporting Annexes o Pre-operational conditions o Improvement conditions o Consultation responses Intertissue Neath Page 4 of 51 EPR/BU2489IT/V009 Glossary of acronyms used in this document (Please note that this glossary is standard for our decision documents and therefore not all these acronyms are necessarily used in this document.) APC Air Pollution Control BAT Best Available Technique(s) BAT-AEL BAT Associated Emission Level BREF BAT Reference Note CEM Continuous emissions monitor CFD Computerised fluid dynamics CHP Combined heat and power COMEAP Committee on the Medical Effects of Air Pollutants COT Committee on Toxicity of Chemicals in Food, Consumer Products and the Environment CROW Countryside and rights of way Act 2000 CV Calorific value CW Clinical waste CWI Clinical waste incinerator DAA Directly associated activity – Additional activities necessary to be carried out to allow the principal activity to be carried out DD Decision document EAL Environmental assessment level ELV Emission limit value EMAS EU Eco Management and Audit Scheme EMS Environmental Management System EPR Environmental Permitting (England and Wales) Regulations 2010 (SI 2010 No. 675) as amended EQS Environmental quality standard EU-EQS European Union Environmental Quality Standard EWC European waste catalogue FSA Food Standards Agency GWP Global Warming Potential HHRAP Human Health Risk Assessment Protocol HRA Human Rights Act 1998 HW Hazardous waste HWI Hazardous waste incinerator Intertissue Neath Page 5 of 51 EPR/BU2489IT/V009 IBA Incinerator Bottom Ash IED Industrial Emissions Directive (2010/75/EU) IPPCD Integrated Pollution Prevention and Control Directive (2008/1/EC) – now superseded by IED I-TEF Toxic Equivalent Factors set out in Annex VI Part 2 of IED I-TEQ Toxic Equivalent Quotient calculated using I-TEF LCPD Large Combustion Plant Directive (2001/80/EC) – now superseded by IED LCV Lower calorific value – also termed net calorific value LHB Local Health Board LOI Loss on Ignition MBT Mechanical biological treatment MSW Municipal Solid Waste MWI Municipal waste incinerator NOx Oxides of nitrogen (NO plus NO2 expressed as NO2) Opra Operator Performance Risk Appraisal PAH Polycyclic aromatic hydrocarbons PC Process Contribution PCB Polychlorinated biphenyls PCT Primary Care Trust PEC Predicted Environmental Concentration PHW Public Health Wales POP(s) Persistent organic pollutant(s) PPS Public participation statement PR Public register PXDD Poly-halogenated di-benzo-p-dioxins PXB Poly-halogenated biphenyls PXDF Poly-halogenated di-benzo furans RDF Refuse derived fuel RGS Regulatory Guidance Series SAC Special Area of Conservation SED Solvent Emissions Directive (1999/13/EC) – now superseded by IED SCR Selective catalytic reduction SGN Sector guidance note SHPI(s) Site(s) of High Public Interest Intertissue Neath Page 6 of 51 EPR/BU2489IT/V009 SNCR Selective non-catalytic reduction SPA(s) Special Protection Area(s) SS Sewage sludge SSSI(s) Site(s) of Special Scientific Interest SWMA Specified waste management activity SWCP Small Waste Co-incineration Plant TDI Tolerable daily intake TEF Toxic Equivalent Factors TGN Technical guidance note TOC Total Organic Carbon UHV Upper heating value –also termed gross calorific value UN_ECE United Nations Environmental Commission for Europe US EPA United States Environmental Protection Agency WHO World Health Organisation WID Waste Incineration Directive (2000/76/EC) – now superseded by IED Intertissue Neath Page 7 of 51 EPR/BU2489IT/V009 1 Our decision We have decided to issue the variation to the applicant. This will allow it to operate the installation, subject to the conditions in the consolidated permit. We consider that, in reaching that decision, we have taken into account all relevant considerations and legal requirements and that the permit will ensure that a high level of protection is provided for the environment and human health. This application is to operate an installation which is subject principally to the Industrial Emissions Directive (IED). The consolidated permit contains many conditions taken from our standard Environmental Permit template including the relevant Annexes. We developed these conditions in consultation with industry, having regard to the legal requirements of the Environmental Permitting Regulations and other relevant legislation. This document does not therefore include an explanation for these standard conditions. Where they are included in the consolidated permit, we have considered the application and accepted the details are sufficient and satisfactory to make the standard condition appropriate. Intertissue Neath Page 8 of 51 EPR/BU2489IT/V009 2 How we reached our decision 2.1 Receipt of Application The application was duly made on 14th December 2015. This means we considered it was in the correct form and contained sufficient information for us to begin our determination. The applicant made no claim for commercial confidentiality. We have not received any information in relation to the application that appears to be confidential in relation to any party. 2.2 Consultation on the Application We carried out consultation on the application in accordance with the EPR, our statutory PPS and our Regulatory Guidance Note RGN6 for Determinations involving Sites of High Public Interest. We consider that this process satisfies the requirements of the Aarhus Convention on Access to Information, Public Participation in Decision-Making and Access to Justice in Environmental Matters, which are directly incorporated into the IED, which applies to the installation and the application. We have also taken into account our obligations under the Local Democracy, Economic Development and Construction Act 2009 (particularly Section 23). This requires us, where we consider it appropriate, to take such steps as we consider appropriate to secure the involvement of representatives of interested persons in the exercise of our functions, by providing them with information, consulting them or involving them in any other way. In this case,